Companies choose how they share your personal information. This notice provides information about how we collect, share, and protect your personal information, and how you might choose to limit our ability to share certain information about you. Please read this notice carefully.

All financial companies need to share customers’ personal information to run their everyday businesses. Accordingly, information, confidential and proprietary, plays an important role in the success of our business.  However, we recognize that you have entrusted us with your personal and financial data, and we recognize our obligation to keep this information secure. Maintaining your privacy is important to us, and we hold ourselves to a high standard in its safekeeping and use. Most importantly, Zoom Casa does not sell its customers’ non-public personal information to any third parties. Zoom Casa uses its customers’ non-public personal information primarily to complete financial transactions that its customers request or to make its customers aware of other financial products and services offered by a Zoom Casa affiliated company.

Zoom Casa may collect non-public information about you from the following sources:

• Information we receive about you on applications or other forms;
•  Information you may give us orally;
•  Information about your transactions with us or others;
•  Information you submit to us in correspondence, including emails or other electronic communications; and
• Information about any bank account you use for transfers between your bank account and any Fund account, including
  information provided when effecting wire transfers.

Zoom Casa does not disclose any non-public personal information about our customers or former customers without the customer’s authorization, except that we may disclose the information listed above, as follows:

• It may be necessary for Zoom Casa to provide information to unaffiliated third parties in connection with our performance of the services we have agreed to provide you. For example, it might be necessary to do so in order to process transactions and maintain accounts.
• Zoom Casa will release any of the non-public information listed above about a customer if directed to do so by that customer or if Zoom Casa is authorized by law to do so, such as in the case of a court order, legal investigation, or other properly executed governmental request.
• In order to alert a customer to other financial products and services offered by an affiliate, Zoom Casa may share information with an affiliate, including companies using the Zoom Casa name. Such products and services may include, for example, other investment products offered by a Zoom Casa company.  If you prefer that we not disclose non-public personal information about you to our affiliates for this purpose, you may direct us not to make such disclosures (other than disclosures permitted by law) by calling 1 (833) 996-6227. If you limit this sharing and you have a joint account, your decision will be applied to all owners of the account.

We will limit access to your personal account information to those agents and vendors who need to know that information to provide products and services to you. Your information is not provided by us to nonaffiliated third parties for marketing purposes. We maintain physical, electronic, and procedural safeguards to guard your non-public personal information.

As required by federal law, Zoom Casa will notify customers of Zoom Casa’s Privacy Policy annually. Zoom Casa reserves the right to modify this policy at any time, but in the event that there is a change, Zoom Casa will promptly inform its customers of that change.